Interrogatories 2 plaintiffs 213f interrogatories and 214 requests to produce in products liability case

Robert A. Clifford, Attorney for Plaintiff, Kevin P. Durkin, Richard F. Burke, Jr., Shannon M. McNulty, Colin H. Dunn, Clifford Law Offices, P.C., 120 N. Lasalle Street, 31st Floor, Chicago Illinois 60602, (312) 899-9090, Atty. No.: 32640.

Plaintiff JENNIFER E. GARLAND, Independent Administrator of the Estate of SCOTT A. GARLAND, Deceased, through her attorneys, CLIFFORD LAW OFFICES, P.C., pursuant to Supreme Court Rule 213, propounds the following Interrogatories to the Defendants, TELEDYNE INDUSTRIES, INC., TELEDYNE CONTINENTAL MOTORS, TELEDYNE TECHNOLOGIES, INC., TDY INDUSTRIES, INC., T.W. SMITH ENGINE CO., INC., SYBARIS CLUBS INTERNATIONAL, INC., SYBARIS VENTURES ONE, LLC, H.K. GOLDEN EAGLE, INC., RANDELL D. REPKE, Independent Executor of the Estate of KENNETH C. KNUDSON, GALT AIRPORT, L.L.C., MORGAN STANLEY & CO., INC., and DONNA TUREK, as Independent Administrator of the Estate of MARK TUREK, to be answered within twenty-eight (28) days:

1. Pursuant to Supreme Court Rule 213(f)(1), identify any and all “lay witnesses” who will testify at trial on behalf of the Defendant. As to each witness state:

a. The identity and address of the witness.

b. The subjects on which the witness will testify.

ANSWER:

2. Pursuant to Supreme Court Rule 213 (f(2), identify any and all “independent expert witnesses” who will testify at trial on behalf of the Defendant. As to each witness, state:

a. The identity and address of the witness.

b. The subjects on which the witness will testify.

c. The opinions Defendant expect to elicit from the witness.

d. If known, the bases for each opinion and the facts the witness believes supports each opinion.

e. State the date or approximate date on which the conclusions and opinions identified in (c) were first expressed or made known to you.

ANSWER:

3. Pursuant to Supreme Court Rule 213(f)(3), identify any and all “controlled expert witnesses” who will testify at time of trial on behalf of the Defendant. As to each witness, state the following:

a. Identity and address.

b. Area(s) of expertise.

c. The subject matter on which the witness will testify.

d. The conclusions and opinions of the witness and the bases therefore.

e. The qualifications for each witness and attach a curriculum vitae pursuant to Supreme Court Rule 214.

f. Identify each and every report prepared by each expert or opinion witness identified above, indicating whether this report was submitted in oral form, written form, or both, pursuant to Supreme Court Rule 213(f)(3), and provide a complete copy of the expert witness' report, if in written form, pursuant to Supreme Court Rule 214.

g. Identify, with particularity any and all statements, reports, letters, medical records (including x-rays), tape recordings, photographs, memoranda, or documentation of any type reviewed by each person and the date on which these materials were provided to the witness.

h. State the name, author, publisher, page and date of publishing of all texts, articles, journals or medical literature upon which any witness relied, consulted in connection with review of this matter, or may use or refer to at trial, or which Defendants otherwise intend to use at trial.

i. State the date or approximate date on which the conclusions and opinions identified in (d) were first expressed or made known to you.

j. State with particularity all other information verbally furnished to each witness for consideration.

ANSWER:

4. Identify (and, pursuant to Supreme Court Rule 214, produce legible copies of) all correspondence or other written communication between each witness and Defendant's counsel or anyone acting on Defendant's behalf in regard to this action.

ANSWER:

5. Did any witness(es) identified in the Answers to Interrogatory Nos. 1, 2, and/or 3, at any time, prepare any notes, memoranda, summaries or other writings in connection with this matter? If so, (a) identify each such writing; and (b) pursuant to Supreme Court Rule 214, produce legible copies of all such wrings

ANSWER: